HomeMy WebLinkAboutSUPPLEMENTAL ITEM #4 RECEIVED AFTER REVIEW PERIOD AND 4-24-18 PC MEETING Draft EIR Related Communication
Received After Review Period
And
For April 24, 2018 Planning Commission Meeting
Draft EIR Related Communication
Received After Review Period
And
For April 24, 2018 Planning Commission Meeting
LTR. Date Commenter Comment Response/Status
Received
R2 4-16-18 Collette L. Letter(attached) regarding The communication and
Morse additional communication responses will be shared with the
Resident- City's decision-makers for
145 N, C consideration (see attached)
Street
Comment Letter R2 received from Collette Morse, dated April 16, 2018 (3 pages)
April 16,20I8 Submitted via Ismail to Mr.Dana Ogdoa,AICP
Chairperson Smith and Members of the Planning Commission
City of Tustin
340 Centennial Way
Tustin,CA 92784
Subject: Public Comments Regarding the Downtown Commercial Core Speciflc Plan and
Environmental Impact Report for April 24,2018 rlauning'Commissiou Meeting•
Dear Chairperson Smith and Members of the Planning Commission
I was at City Hall on April 10,2018 for the Planning Commission meeting,but was told by staff that the
meeting was cancelled due to lack of a quorum and that it would be continued to April 24,2018.I am
unable to attend the April 24,2018 meeting in person due aprevious commitment,so I am providing you
with written comments.
I'm a 20+year resident of Tustin and I'm happy to see some love and attention being paid to this part'of
the City.I have paitielpated in this process since 2014,including attending all three community workshops.
R2-1
Need for Additional Community Workshop or Open House
The process and plan for this area of the City is important and the vision should be shared and clearly
understood by all.I believe-this process would have benet"rtted fmrd a 4's community workshoor open
house to share the proposed land use,design,circulation,and other improvementps before the Draft Specific
Plan and EIR were released for public review,particularly given the time that has Iapsed between the
January 2016 oommunity workshop and this hearing tonight.
The process felt genuine and inclusive at the beginning with the three community workshops. Those
qualities were lost with the project delay.It would be a win-win for all if additional opportunities forpublic
engagement and participation prior to Planning Commission of City Council action on the Specific Plan
and Environmental Impact Report are provided at an open house or communityworkshop.
Specific Plan and Environmental Impact Report
Overall,I am supportive of the land use and design changes proposed in the Specific Plan.But I do not
support the proposed Circulation Element and Master Plan of Arterial Highway changes to 11� 2",31a and
Main Streets. 1 R2-2
- I support traffic calriting measures on Ist'Street.I support bus mutes and-easy access to bus stops ori the
routes.'I support protected bike lanes for cyclists.I support wider sidewalks for pedestrians.But I do not
support the loss of two travel lanes on 19 Street
1
ChabTeieon Snifth and Members ofthe Planning COmmission Page 2
City of Tustin
April I6,2018
I do not believe 1"Street is the appropriate street to apply the proposed changes.eased on 2016 counts,l a
Street accommodates between 14 and 20,000 daily trips from Newport to Tustin.The current designation
of a primary arterial-a 4-lane divided roadway-is designed to accommodate between 20 to 30,000 daily
trips.Changing the designation to a divided collector--a 2-lane divided roadway-which-is designed to
accommodate between 9 to 15,000 daily trips is not appropriate and does not provide sufficient capacity to
accommodate current daily trips nor the additional trips from the proposed Speclflc Plan.
The proposed CirculatiorrElement changes will result in a redistribution of traffic within and outside of the
Plan area, including increases and intrusion onto residential.streets. The redistribution of trips and
residential intrusiontneighborhood pass-through impacts were not analyzed in the Draft EIR,but absolutely
should be to provide a full understanding of the impacts.
I also do not support changing 21d and 3d Streets to one-way streets.There is a functioning grid system that 122-2 cont
docs not require changing the streets from one travel lane in each direction to one-way streets.
In addition,there will increased delays to make lett turns onto 1•from stopped controlled intersectlons.I
presently experience delays turning left from C Street onto I't that can range anywhere from 15 seconds to
several minutes-and that's in the morning,midday,or afternoon.I'm able to safely make a left tum into
the fust travel lane while other vehicles use the second travel lane.I arrt concemed that with proposed
changes to I n Street that the delay will be increased'or that i won't be able to make a left-tum at all.
Also, 1°Street is an important bus route with bus stops at I.arwin-Square andTYrstirl trourtyard, and
connections to routes on Newport.OCTA will not be able to maintain timely bus routes with the loss of
two travel lanes.I'm often behind abus inthe second travel lane.With only one travel lane in each direction,
we will all behind busses and delayed while passengers board or unboard busses.
Need for Protection Against Residential Yntruslon/Neighborhood Pass-Through Traffic
As discussed above,the Aran BIRAid not analyze the residential intrusion/neighborhood pass-through
impacts resulting from the redistribution of trips associated with the proposed circulation element changes.
The following text should be added to the Specific Plan to ensure that residential streets and neighborhoods
do not experience pass-through trips. -3
Text should be added to the Specific Plan as a Plan feature and/or Elft as mitigation regarding a
Neighborhood Traffic Management Plan(NTbT).This Plan could be prepared,implemented,and funded
by the City and/or.by project applicant(s). The Plan should address education, eirforcement, and
enhancement
Notfce of Preparation,Initial Study,and Environmental Impact Report '
The Notice of Preparation and initial Study are silent regarding the proposed amendments to the General
Plan Circulation Element and the grange County Master Plan of Arterial Highways(MPAH)to 14,2°d,3rd,
and Main Streets.However,these amendments are called out in the Environmental Impact Report(EIR) R24Project Description
•This results in aPmjcctDesoripdoninconsistencybetweentheNotice of Preparationlinitial Study(NOPAS)
-- -�-- --
--and the-EIR:`The EIR Project Description includes project components (Le., Circulation Element and
WAH amendments,street modifications/reductions)that were not disclosed in the NOPAS.Neither the
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Chairperson Smith and Members oftho Planning ConimIssion Page 3
Cityof'rirstin
AprU 16,2018
public nor public agencies were afforded the opportunity to understand these project components early in
the EIR process,or offer comments about them and their potential environmental impacts.
R2-4 writ
The Initial Study/NOP identifies a smaller proposed project,particularly related to circulation,then in the
EIR.The scope and scale of the proposed.project should be consistent throughout the CEQA process.This
has not occurred with this EIR process;thus the.lSfROP should be reissued and the Draft MR.should be
revised and recireulated.
EIR Correction
I have one correction to note on Responses to Comments page 2-1 which states my comment letter was
dated April 3,2018 and is noted as late.That information is incorrect and should be revised in the Final R2-5
Elk I submitted my comment letter to Mr.Ogdon on April 2na at 4:31 pm via email.My comment letter
was received prior to the April 2"'5:00 pm deadline.I have an email receipt that the email was delivered at
4:31 pm and an email read receipt that my email was read on April 3'd in the moriting..
Project Notification
I reside within the 300-foot radius of the Plan boundaries;however,my receipt of mailed notices`has been
inconsistent throughout the process.Given riiy location within the 300-foot radius,.I:&uld'have received
till n6tice6 regarding the Specific Plan and Environmental Report. I had also provided my contact.
information at the three community workshops to receive notifications via email or other methods.
I received mailed notices of all three community workshops.But I did not receive mailed notices of the
Notice of Preparation and Scoping Meeting.or the Notice.of Availability of a Draft EIR.I did receive a
mailed notice of the April 10,2018 Planning Commissionmeeting.
I have received three emails—1)Notice of Community Workshop#2,.2)Notice`of Availability,and 3)
April 10,2018 Planning Commission meeting.
Notice Received Mail Notice Received Email Notice R2-8
Community Workshop#1 Yes nla
Community Workshop#2 Yes Yes
Community Workshop 93 Yes No
Notice of Preparation of aDraft EIR NO NO
and Scoping Mee'
Notice ofAvailability of aD aft EIR No Yes
Planning Commission Meeting ril 10 2018 Yes Yes
I have kept all mailed notices and emaels from the City on this project.I did not receive several mailed
notices, and that has limited my ability to participate in and provide inputteomments throbghoi t this
Specific Plan and EIR process.
Sincerely,
Collette L.Morse
145-N C Street
T uslin,.CA 92780
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Response to Comment Letter R2 from Collette Morse,dated April 16, 2018
Comment R2-1:The commenter believes that the City should have provided an additional community
workshop or open house on the Specific Plan prior to public hearings on the Specific Plan and EIR because
of the time delay between the last community workshop and the public review the draft of the Down Town
Commercial Core Draft Specific Plan (DCCSP) and Draft EIR.
Response R2-1:This is not a comment on the adequacy of the DCCSP EIR.The community visioning and
three workshops were conducted over a period of about two years followed by the preparation of the
Draft Specific Plan that reflects the community's vision for the DCC and the Draft EIR that analyzes its
impacts.Additional Planning Commission and City Council update meetings occurred during the
preparation of the Specific Plan and EIR.The Planning Commission and City Council will also hold public
hearings on the Specific Plan and EIR; therefore, no further workshops are needed.
Comment R2-2: The commenter states that overall,she is supportive of the DCCSP,including easy access
to bus stops, protected bike lanes for cyclists, and wider sidewalks for pedestrians but not of the changes
to the Circulation Element,the MPAH, and most of the conceptual changes to First Street,Second Street,
Third Street,or to Main Street.
Response 1112-2: To enhance conditions for pedestrians, bicyclists and transit users,the DCCSP proposes a
transformation of the existing roadways to create"complete streets" in which the roadway design gives
pedestrians and bicyclists greater emphasis.To provide the maximum amount of flexibility to design
spaces for pedestrians and bicyclists, changes to the City's Circulation Element and the County MPAH are
needed to reclassify First Street and Main Street to collector roadways.With the reclassification,the City
will not be constrained by the current MPAH designations,which requires two vehicular travel lanes in each
direction, including at locations where the two lanes of capacity are not needed.A comprehensive traffic
study was prepared for the DCCSP,which shows that First Street,Second Street,Third Street, and Main
Street would continue to operate with vehicular levels of service of "A" and "B" with the proposed
roadway changes (DEIR Table 5.9-3: Existing plus Project Intersection Level of Service).
With slower speeds on First Street,the traffic forecasting model utilized for the DCCSP traffic study
estimates that more through traffic will instead utilize Irvine Boulevard,which has sufficient capacity to
accommodate more trips at higher speeds than can be achieved on First Street.Average daily traffic
(ADT).volumes on First Street are.forecast to reduce from approximately 17,000 ADT to 15,000 ADT (DEIR
Appendix E, Figure 3: Existing ADT Volumes and Figure 4:Existing plus Project ADT Volumes) due to the
modifications to first Street.The U.S.-Department of Transportation Federal Highway Administration
(FHWA) advises that roadways with ADT of 20,000 ADT or less may be good candidates for a "Road
Diet" in which two through Panes and a center left-turn lane are provided (FHWA, Road Diet Informational
Guide, November 2014).
As noted above,the traffic forecasting model utilized for the DCCSP traffic study was used to estimate the
amount of traffic that would be diverted to other roadways due to modifications to First Street.With the
diversion,each of the arterial roadways in the DCCSP area continue to operate at level of service "C" or
better (DEIR Table 5.9-3: Existing plus Project Intersection Level of Service).As such, diversion of through
traffic onto local streets is not anticipated.The DCCSP traffic study also addressed the conversion of
Second Street and Third Street to one-way streets,which likewise indicates acceptable levels of service
will result since sufficient capacity is provided on the arterial roadways.The conversion'.to one-way streets
provides additional options to roadway configurations to enhance conditions for pedestrians, bicyclists,
and parking.
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The functionality of First Street after conversion to a two-lane roadway with center turn-lane will be
comparable to the current Main Street configuration.
Finally,the traffic study addressed the conceptual improvements to Main Street (spanning DA-4 and DA-5)
that involve: reducing the number of traffic lanes and lane widths, adding parking, a bike lane, an
expanded pedestrian sidewalk, and installing an entry arch spanning the street.The functionality will be
comparable to other portions of Main Street that are already one-lane in each direction (from the
westerly City limit to Newport Avenue).
Vehicles making turns to and from the side streets will benefit from gaps created by traffic signals
upstream and downstream and,if necessary, can be aided by treatments such as all-way stop control.The
specific configuration of future changes to First Street will be informed by a corridor specific traffic study
in order to balance the needs of all users. For example,turnouts can be provided for OCTA buses so that
traffic can safely pass the bus while loading and unloading passengers.
Comment R2-3:The commenter is concerned with passthrough trips and residential intrusion as a result of
the proposed Circulation Element changes.The,commenter believes the Draft EIR failed to analyze these
impacts and that a neighborhood traffic calming plan is needed,either as part of Specific Plan or as EIR
mitigation.
Response 112-3:As noted in Response 2, above,the traffic forecasting model utilized for the DCCSP
traffic study was used to estimate the amount of traffic that would be diverted to other roadways due to
modifications to First Street.With the diversion,each of the arterial roadways in the DCCSP area continue
to operate at level of service "C" or better (DEIR Table 5.9-3: Existing plus Project Intersection Level of
Service).As such, diversion of through traffic onto local streets is not anticipated since sufficient capacity is
provided on the arterial roadways. Impacts were determined to be less than significant. EIRs are not
required to discuss mitigation measures for less than significant environmental impacts.The commenter has
not submitted substantial evidence into the record that a neighborhood traffic calming plan is needed.As
discussed in Response R2-2,there is no pending project and specific configuration of future changes to First
Street. Future changes will be informed by a corridor specific traffic study; the potential for localized
impacts will continue to be addressed on a project-by-project basis, and are discretionary projects subject
to CEQA, at such time that they are proposed.
Comment R24:The commenter asserts that since some of the circulation improvements were not
specifically identified in the Notice of Preparation (NOP),that other public agencies were not afforded the
ability to comment early in the EIR process.Furthermore,commenter asserts that the project description in
the NOP was of a "smaller proposed project" and as a result,the Initial Study/NOP should be reissued
and the Draft EIR recirculated.
Response R24:The Initial Study/NOP stated that"the vision focuses on continuing to ensure an
economically vital,walkable, bikeable, mixed-use center with a focus on active ground floor retail and
office environments."The Initial Study/NOP also stated that"the Specific Plan includes provisions for
- enhancing the.public.reajm as an opportunity of public space and streets as a place for people." The
improvements to the Circulation Element,the MPAH, and the conceptual changes to First Street,Second
Street,Third Street, and Main Street are minor modification to the project description;they represent the
specific mechanisms that emerged as necessary to implement the City's and Community's vision for a
walkable, pedestrian friendly DCC.As discussed in Response to Comment 2 and Response to Comment 3,
the circulation network changes were evaluated as part of the Draft EIR and impacts were found to be less
than significant without mitigation.
If a project is changed while the EIR is being prepared and the change will result in new significant
impacts,the lead agency may add the information to the EIR and must circulate the new information for
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public review and comment if recirculation is required under Public Resources Code §21092.1.
Recirculation is not required if the additions or modifications to an EIR do not!involve a new significant
environmental impact, a substantial increase in the severity of on environmental impact, or new alternatives
or mitigation measures for significant impacts that the project proponents decline to adopt. Recirculation is
not required when the changes merely clarify, amplify,or make insignificant modifications to an adequate
EIR.
Here, the minor modifications to the project description didl not result in significant new impacts, were
included in the Draft EiR, circulated for public review, and public agencies had the opportunity to comment
on the Draft EIR. Therefore, the Draft EIR is legally adequate and recirculation is not required.
Comment R2-5: The commenter correctly notes that the Response to Comments page erroneously
identified her comment letter as having been submitted late on, April 3, 2018 and asks for it to be
corrected.
Response R2-5: Correction made. The commenter's letter, was received on April 2, 2018.
Comment R2-6: The commenter claims that not received notices in both electronic and physical mail has
limited her ability to participate and comment on the Specific Plan and Draft BR.
Response R2-6.- The commenter's email and physical imail address were provided to the City as port of
the community workshops for the Specific Plan. The commenter confirms that she has received either an
eiectric or physical notice, or both, of: every workshop, the Draft EIR Notice of Availability, and the
Planning Commission hearing.As discussed above,the commenter sent in ai timely comment letter on the
Draft EIR. The commenter has, failed to demonstrate how not receiving the notices in both electronic and
physical mail; has limited her ability to participate and comment on the project.
The City sent the IS/NOP and Notice of Scoping meeting to all public agencies with authority over the
project or resources affected by the project, as required by CEQA, per Public Resources Code section
21080.4. The commenter does not represent a public agency and did not receive an individual iS/NOtP
and Scoping meeting notice.Although the lead agency may consult with members of the public who have
made a written request to be consulted on the project, the agency is not required to do so per Public
Resources Code Sections 21104(a) and 21153.
Furthermore, the NOP was posted at the Orange County, Clerk-Recorder's office on August 2, 2016. The
notice was published in the August 1, 2016 Orange County Register, a newspaper of general circulation.
Copies of the IS/NOP were made available for public review at the City of Tustin Community
Development Department, located at 300 Centennial Way, and it was available on the City's website:
htipg//www.tys.ti�g,org/.depLs/gOJAla-nn—,n-s"u-&Le--o5.p. Therefore, the City followed, and is in compliance
with CEQA procedural public disclosure requirements and the commenter was not deprived of the ability to
participate and comment.
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